Missouri Workers' Compensation Decisions

The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award allowing workers' compensation benefits to Theresa Thompson for a low back injury sustained on July 20, 2010 while lifting and shelving copper coils. The claimant was entitled to temporary total disability benefits, permanent partial disability compensation, and medical aid totaling over $223,000, with additional underpayment and back pay amounts owed.

The Labor and Industrial Relations Commission affirmed the administrative law judge's award granting permanent total disability compensation to Donald Brown for his work-related injuries to his back and left elbow. The Commission rejected the Second Injury Fund's argument that an anxiety disability should be considered in the PTD determination, finding that non-qualifying psychiatric disabilities need not be factored into the analysis.

The Commission modified its prior award regarding permanent partial disability benefits calculation following a court mandate to recalculate based on full-time worker standards. The employer is now liable for $16,320.00 in permanent partial disability benefits at a rate of $204.00 per week for 80 weeks, with the Second Injury Fund liable for an additional $9,424.80 in enhanced benefits.

The Commission reversed the ALJ's decision denying permanent total disability (PTD) benefits from the Second Injury Fund for an employee who sustained a compensable work-related cervical spine injury on February 28, 2018, and subsequently underwent surgery at C5-6 and C6-7. The employee settled his claim against the employer for 15% permanent partial disability of the body as a whole referable to the cervical spine and has been unable to work since May 2018.

The Commission modified the ALJ's award to allow compensation for unpaid past medical expenses for employee Rodney Battles, who sustained a work-related back injury on October 5, 2016, requiring two back surgeries. The decision clarifies that an employer's duty to provide statutorily-required medical aid is absolute and unqualified under Missouri workers' compensation law.

The Labor and Industrial Relations Commission affirmed the Administrative Law Judge's award allowing workers' compensation benefits for Jason L. Collins' occupational disease claim involving cumulative trauma to his back and right lower extremity sustained while employed as a truck driver/laborer. The Commission rejected the employer's argument that an untimely answer resulted in admission of all facts including legal conclusions about whether the injury arose out of employment.